Regulatory Alerts2006-02-14
Added
Frequently Asked Question regarding Customer Identification Programs for Futures Commission Merchants and Introducing Brokers (31 CFR 103.123)
Futures commission merchants are not required to treat beneficial owners as customers for purposes of 31 CFR 103.123 when transactions occur through omnibus or sub-accounts established by financial intermediaries. Under these conditions, where the intermediary holds the account, initiates all transactions, and the beneficial owner has no direct control, the financial intermediary is treated as the customer. This guidance clarifies that futures commission merchants are not required to look through the intermediary to the underlying beneficiaries in such arrangements.
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